Subject: File No. S7-14-08
From: Rick Carlson
Affiliation: Financial Advisor

August 26, 2008

I agree with the SEC's decision - I see these EIA's as an overhyped and abused product by many insurance professionals - I think the product would best be served to be a registered security and therefore only sold by true financial professionals - The EIA's are marketed to insurance and financial professionals as a windfall for commissions for the producer with long surrenders for the client - The products are getting better, but still the hype is there and quite frankly variable annuities are more competitive then these pieces of overhyped junk (the EIA)

I would get 10 phone calls a month trying to get me to sell these things and I just couldn't stand the thought of doing so after I sold 2 or 3 of them

After doing my due diligence and irking many marketing companies by calling the product "pieces of crap", I was all for the product to become a registered product - I can't wait to have these products re-registered with financial professionals or to force these "agents" to become securities licensed

Good call gentlemen - There are better and cheaper alternatives out there for clients

The only winner when selling this product was the producer who usually received bonuses and a 10% payout -